MIPS Manual 2017—Coming to Grips With MIPS

On March 26, 2015, just before a 2-week recess, Congress eliminated the long-despised sustainable growth rate (SGR) formula by passing H.R. 2, the Medicare Access and CHIP Reauthorization Act (MACRA). And as the legislators filed out of the chamber in the south wing on the way to a vacation, I can imagine them releasing a collective sigh of relief knowing that (finally) they had done away with the annual SGR ritual. No more phone calls from constituent ophthalmologists about repealing the flawed SGR. And now we have MACRA and its Merit-Based Incentive Payment System (MIPS).

Twenty months after SGR was repealed, the Republicans swept the 2016 elections and many physicians wondered what that might mean for MIPS. Some asked whether MIPS reporting would go away if Obamacare was repealed, associating MACRA/MIPS with the Affordable Care Act (ACA), and indeed, the 2 statutes were designed to go hand in hand. However, nearly everyone was in favor of replacing the SGR: MACRA passed with a vote of 392-37 in the House and 92-8 in the Senate, making it perhaps the most bipartisan action of Congress in years—something that could not be said about the ACA.

Changes to MACRA and MIPS are much more likely to occur on the regulatory side. Indeed, a degree of regulatory leeway was built into MIPS for the first 2 performance years (2017 and 2018). For example, CMS revised the MIPS requirements for 2017 by implementing a pick your pace approach as a transition to full MIPS reporting. This year, to avoid the 4% reimbursement penalty in 2019, physicians only need to report on 1 quality measure or 1 improvement activity or the advancing care information (ACI) base score measures. If reporting a quality measure, they only need to report it once on 1 patient to avoid the penalty; if performing an improvement activity or the ACI base score measures, they need to do so for 90 days. However, a minimalist approach to reporting leaves no margin for error.

The Academy urges ophthalmologists to fully participate in MIPS reporting this year because it is a great opportunity to learn the nuances of reporting with very little risk of a negative outcome. Furthermore, you might qualify for the exceptional performance bonus if you report on all 3 of this year’s performance categories: quality (which replaces PQRS), ACI (which replaces the meaningful use program), and improvement activities. If you don’t have an electronic health record (EHR) system you may earn a small bonus, but unless you are exempt from ACI, it would take a near perfect performance to earn the exceptional performance bonus.

Some practices will choose to report MIPS as a group instead of the individual clinicians each reporting separately. The clinicians in the group report the same quality measures, the same ACI measures, and the same improvement activities, and they all get a single 2017 final score. There are some advantages to group reporting. For example, if just 1 clinician in the group performs an improvement activity, that activity contributes to the group’s final score and everybody benefits. The group’s 2017 final score determines the 2019 payment adjustments for all members of the group.

It is likely that MIPS and MACRA will be a continuing reality for ophthalmologists. As this MIPS Manual went to press, CMS published its proposed MIPS rules for 2018. It has asked for feedback and probably won’t finalize the rules until October or November. Some of the proposed rules are a step forward (e.g., bonus points for managing complex cases); others are a step back (e.g., reduced credit for quality measures that are “topped out”). After the Academy has finished assessing how the proposals would impact ophthalmologists and their patients, it will make its case to CMS.

In the meantime, you should make the most of 2017. Because of the relaxed pick your pace requirements, you have an opportunity to refine reporting processes and assess MIPS readiness with little risk of a negative payment adjustment.

I’ve read a lot on the internet about MIPS, and EyeNetMagazine has the most concise, accurate, and understandable information available on MIPS for ophthalmologists. EyeNet’s 5-part series on MIPS was terrific and this MIPS supplement provides all the information in 1 place. Save this booklet; it could be a valuable reference resource all year.

Note: Meeting regulatory requirements is a complicated process involving continually changing rules and the application of judgment to factual situations. The Academy does not guarantee or warrant that regulators and public or private payers will agree with the Academy’s information or recommendations. The Academy shall not be liable to you or any other party to any extent whatsoever for errors in, or omissions from, any such information provided by the Academy, its employees, agents, or representatives.